Justia Civil Rights Opinion Summaries

A man was shot and killed in his jewelry shop in 1983, and Decedent was sentenced to death for the crime. Thirty years later, Louisiana vacated Decedent’s conviction because new evidence identified the real murderer. After his release from prison, Decedent filed a Section 1983 suit seeking damages from police officers, prosecutors, and the local government for suppressing, fabricating, and destroying evidence. Decedent died shortly thereafter, leaving Plaintiff as the executrix of his estate. In 2021, the district court dismissed Plaintiff’s amended complaint in its entirety based on Fed. R. Civ. P. 12(b)(6) as to some defendants and 12(c) as to others.   The Fifth Circuit affirmed. The court explained that Plaintiff brought a traditional negligence claim. Louisiana uses the typical reasonable-person standard to assess an individual’s liability for negligence. For the same reasons that Plaintiff did not adequately plead constitutional violations due to the defendants’ suppression, fabrication, and destruction of evidence, she also fails to plead sufficient factual matter to show that they violated the standard of care of a reasonable officer. Accordingly, the court found that the district court thus properly dismissed this claim. View "Armstrong v. Ashley" on Justia Law

Plaintiff was detained beyond the expiration of his sentence. After his release, he sought redress for this violation of his rights by bringing a lawsuit against various Louisiana officials under 42 U.S.C. Section 1983 and Louisiana state law. The district court dismissed most of Plaintiff’s claims but allowed a supervisory liability claim against Department Secretary James LeBlanc to proceed by denying qualified immunity. Secretary LeBlanc appealed the denial of qualified immunity, arguing that his conduct wasn’t objectively unreasonable in light of clearly established law.   The Fifth Circuit reversed. The court reasoned that the right to timely release is clearly established. But Plaintiff failed to adequately brief—and has thus forfeited—any meritorious argument that Secretary LeBlanc’s behavior was objectively unreasonable in light of that right. The court explained that to the extent that Plaintiff argues the merits, it’s inadequately briefed. Plaintiff’s entire presentation on the issue of objective unreasonableness amounts to just this single conclusory statement: “It is inherently unreasonable for the secretary . . . to fail to enact policies and procedures to ensure the prompt release of inmates who have served their sentences in accordance to the law.” A single, unsupported sentence isn’t enough to adequately brief the issue. View "Taylor v. LeBlanc" on Justia Law

The decedent committed suicide in his cell. On behalf of her minor child, Plaintiff sued the warden at Ouachita Correctional Center (“OCC”) and the sheriff of Ouachita Parish in their official capacities; she also purports to have sued them in their individual capacities. All federal claims are brought under 42 U.S.C. Section 1983 for violations of the decedent’s Eighth Amendment rights. Plaintiff additionally sued under related state laws for negligence and vicarious liability. The district court granted summary judgment.   The Fifth Circuit affirmed. The court explained the warden cannot be sued in his official capacity. Official-capacity suits may be brought only against an official acting as a policymaker. Further, although the sheriff can be sued in his official capacity, those claims also fail. The Sheriff, as the final policymaker in the Parish, does satisfy the second requirement of the analysis and can be sued in his official capacity, assuming Plaintiff provides evidence that the conduct prong is met. However, Section 1983 does not allow recovery under a theory of respondeat superior; a plaintiff must show that the local government’s policy or custom violated the plaintiff’s constitutional rights. Moreover, the court explained that even if Plaintiff adequately pleaded her individual-capacity claims, she has not alleged a genuine dispute as to any material fact to hold defendants responsible under a supervisory-liability theory. View "Guillot v. Russell" on Justia Law

Plaintiff, proceeding pro se, filed a lawsuit in Texas state court against several officials at the Texas Department of Criminal Justice, where he remains an inmate. He alleged violations of his First and Eighth Amendment rights under 42 U.S.C. Section 1983 arising out of a housing transfer and subsequent physical altercation. According to Plaintiff, he had previously been sexually harassed and threatened by inmates in boot camp housing; after asking the sergeant for a transfer to the main building on account of the harassment and threats, he was assigned housing in the main building. Defendants removed the case to federal court, whereupon the district court granted their motion to dismiss all of Plaintiff's claims except for two: his First Amendment retaliation and Eighth Amendment failure-to-protect claims. The district court granted Defendant’s motion for summary judgment on qualified immunity grounds. The district court dismissed Plaintiff’s remaining claims with prejudice, and he appealed.   The Fifth Circuit reversed in part and affirmed the district court’s summary judgment dismissal of Plaintiff’s First Amendment retaliation claim. The court reasoned that the facts are consistent with Plaintiff’s allegation that Defendant transferred Plaintiff back to boot camp housing to teach him a lesson about seeking housing transfers from other officials, knowing that he faced a substantial risk of being assaulted by the inmates who he had previously reported to prison officials during the officer protection investigation. The court concluded that this statement is sufficient to create a genuine material factual dispute. However, the court did not decide whether, given this factual dispute, Defendant violated clearly established law. View "Luna v. Davis" on Justia Law

This case concerns attorney misconduct in the Court-Supervised Settlement Program established in the wake of the 2010 Deepwater Horizon oil rig disaster. Appellant, a Louisiana attorney representing oil spill claimants in the settlement program, was accused of funneling money to a settlement program staff attorney through improper referral payments. In a disciplinary proceeding, the en banc Eastern District of Louisiana found that Appellant’s actions violated the Louisiana Rules of Professional Conduct and suspended him from practicing law before the Eastern District of Louisiana for one year. Appellant appealed, arguing that the en banc court misapplied the Louisiana Rules of Professional Conduct and abused its discretion by imposing an excessive sanction.   The Fifth Circuit reversed the en banc court’s order suspending Appellant from the practice of law for one year each for violations of Rule 1.5(e) and 8.4(a). The court affirmed the en banc court’s holding that Appellant violated Rule 8.4(d). Finally, the court remanded to the en banc court for further proceedings, noting on remand, the court is free to impose on Appellant whatever sanction it sees fit for the 8.4(d) violation, including but not limited to its previous one-year suspension. The court explained that the en banc court misapplied Louisiana Rules of Professional Conduct Rule 1.5(e) and 8.4(a) but not Rule 8.4(d). Additionally, the en banc court did not abuse its discretion by imposing a one-year suspension on Appellant for his violation of 8.4(d). View "In re Jonathan Andry" on Justia Law

Plaintiff is a black woman who worked for Lincare, Incorporated. She sued her former employer under Title VII, claiming that she suffered from a racially hostile work environment and that Lincare both failed to address the situation and retaliated against her when she complained. She also sued for breach of contract. The district court granted summary judgment in favor of Lincare. On appeal, Plaintiff contended that summary judgment was improper on her Title VII claims for a hostile work environment and unlawful retaliation.   The Fifth Circuit affirmed. The court explained that even assuming that Plaintiff suffered from severe or pervasive harassment, Lincare cannot be liable under Title VII because it took prompt remedial action. Aside from one remark, Plaintiff could not remember any use of the N-word in the office after she made her reports to HR. Nor does she identify a single racially insensitive comment that occurred after the offending parties received final warnings. In short, Lincare “acted swiftly in taking remedial measures, and the harassment ceased.” Because of its prompt and effective response, Lincare cannot be liable under Title VII for creating a hostile work environment.   Further, the court explained, there is no evidence that Plaintiff’s working conditions were impacted, only that the plan opened up the possibility of further action (which never occurred). An employment decision is not an adverse action if it does not objectively worsen the employee’s working conditions. View "Hudson v. Lincare, Inc." on Justia Law

At its production plant in Baton Rouge, the Exxon Mobil Corporation requires prospective operators to pass an extensive, multi-pronged training program. If they don’t, they’re fired. Plaintiff didn’t pass his tests, so Exxon let him go. Plaintiff then sued Exxon, insisting he wasn’t fairly trained by staff because he’s black. The district court disagreed and dismissed his suit. On appeal, Plaintiff contends that, first, the district court ignored genuine factual disputes and, second, erroneously ruled that he waived his inadequate training theory.   The Fifth Circuit affirmed the district court’s ruling for different reasons. The court explained that Plaintiff cannot rely on an inadequate training theory. Exxon provided Plaintiff with a handbook detailing the polypropylene unit’s processes and equipment, and scheduled time each workweek for him to study. Exxon also assigned him a trainer, an operator with twenty years of experience, who went over the handbook in detail with him. Thus, because his training—and more importantly, his opportunities—paralleled his classmates, his program necessarily couldn’t be inadequate. Without proper training, no terminated trainee is qualified for the position he was training for. Plaintiff satisfied his burden to show he was qualified for the position of operator trainee, the position he was fired from. However, Plaintiff cannot genuinely allege Exxon failed to train him, so he cannot satisfy the McDonnell Douglas framework. View "Rahman v. Exxon Mobil" on Justia Law

In the wake of a 2017 mass shooting in Las Vegas, the Bureau of Alcohol, Tobacco, Firearms, and Explosives, interpreted existing regulations on machineguns as extending to bump stocks. Plaintiff relinquished several bump stocks and then filed this case, seeking to invalidate ATF's interpretation.The district court found in favor of the ATF, as did a panel of Fifth Circuit judges. However, on rehearing en banc, the Eleventh Circuit reversed, finding that "a plain reading of the statutory language, paired with close consideration of the mechanics of a semi-automatic firearm, reveals that a bump stock is excluded from the technical definition of 'machinegun' set forth in the Gun Control Act and National Firearms Act."The court went on to explain that, even if it determine the language to be ambiguous, it would apply the rule of lenity to interpret the statute against imposing criminal liability. Notably, three judges concurred with the court's opinion on lenity grounds, and the opinion also garnered a three-judge dissent. View "Cargill v. Garland" on Justia Law

Plaintiffs’ son was caught in a sting operation conducted by the Internet Crimes Against Children Task Force for the City of Conroe, Texas. Via a dating app, Plaintiffs’ son agreed to meet up with a 14-year-old boy—who was actually an undercover Task Force detective. After circling the meeting spot for two hours, all the while communicating with the detective via the dating app, Plaintiffs’ son was arrested and later charged with online solicitation of a minor. He posted bail and was released. Two days later, Plaintiffs’ son committed suicide by carbon monoxide poisoning. Thereafter, his parents sued numerous defendants in a Section 1983 lawsuit alleging claims for false arrest, malicious prosecution, municipal liability, and state law negligence claims. The district court granted Defendants’ motions to dismiss.   The Fifth Circuit affirmed. The court explained that the district court did not err in granting Defendants’ motions to dismiss. Plaintiffs do not state plausible claims against the detective or the City of Conroe under Sections 1983 and 1985, as the detective had probable cause to arrest Plaintiffs’ son and therefore did not violate his constitutional rights. Plaintiffs’ municipal liability claim against the City of Conroe fails for the same reason. The Wellpath Defendants owed Plaintiffs’ son no duty upon his release from custody, thus defeating the Plaintiffs’ Sections 1983 and 1985 claims against them. And finally, Plaintiffs cannot show the requisite causation to sustain their state law negligence claims. View "Petersen v. Johnson" on Justia Law

Plaintiff worked for a construction company, Performance Contractors (Performance). She sued under Title VII alleging sex discrimination, sexual harassment, and retaliation. The district court granted summary judgment to the construction company. On appeal Plaintiff argued that when Performance prevented her from working at elevation because she was a woman, it effectively demoted her, which amounts to an adverse employment action. Second, Plaintiff argued that her hostile-work environment claim survives summary judgment because Performance knew (or should have known) about the severe or pervasive harassment, and because Performance is not entitled to the Ellerth/Faragher affirmative defense. Third, she argues that a reasonable jury could find that Performance retaliated against her for opposing conduct that she reasonably believed would violate Title VI.   The Fifth Circuit reversed and remanded concluding that Plaintiff raised genuine material fact issues on each claim. The court held that a reasonable jury could find that Plaintiff was suspended and later fired because of her rejection of other employees’ harassment. Further, the court held that Performance was not entitled to summary judgment because reasonable jurors could find that Plaintiff was kept on the ground because she was a woman, and that she otherwise would have been allowed to work at elevation. Moreover, there is a material fact issue about whether Performance effectively implemented its anti-harassment policy. View "Wallace v. Performance Contractors" on Justia Law